ML20203E382
| ML20203E382 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 07/16/1986 |
| From: | Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203E350 | List: |
| References | |
| 70-0398-86-02, 70-398-86-2, NUDOCS 8607240137 | |
| Download: ML20203E382 (8) | |
Text
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w U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
70-398/86-02 Docket No.70-398 License No.
SNM-362 Priority 1
Category UHRD Licensee:
U.S. Department of Commerce National Bureau of Standards Gaithersburg, Maryland 20899 Facility Name: National Bureau of Standards Inspection At: Gaithersburg, Maryland Inspection Conducted:
April 14-17, 1986
~
7 /d/fd Inspector:
J. gh,' Pr6 ject Engineer
/ dat6 Accompanied By:
A. W. Grella Senior He th Physicist (Transportation) lE:HQ Approved By:
/
Op 7 /4 E f.R.Kei g, C f, Safeguards Section, DRSS date Inspection Summary:
Inspection on April 14-17, 1986 (Inspection Report No.
70-398/86-02)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of: organization, training, criticality safety, operations review, radiation protection, radicactive waste management, transportation, environmental pro-tection, emergency preparedness, non-routine events and licensee action on previously identified enforcement items.
Results: No violations were identified. One unresolved item was identified concerning the maintenance of certification documentation required for U.S. 00T 7A shipping containers (paragraph 13.d).
8607240137 860721 REG 1 LIC70 PDR SNM-0362
DETAILS 1.
Persons Contacted L. E. Pevey, Chief, Occupational Health and Safety T. G. Hobbs, Chief, Health Physics L. A. Slaback, Jr., Accelerator and Laboratory Supervisory Health Physicist J. Wang, Reactor Supervisory Health Physicist C. E. Kuyatt, Director, Center for Radiation Research; Chairman, Radiation Safety Committee
- E. Eisenhower, Chief, Office of Radiation Measurement; Chairman, Radiation Safety Review Subcommittee B. L. Frey, Health Physics Secretary
- Not present at the exit interview.
2.
Licensee Action on Previously Identified Enforcement Items (Closed) Inspector Followup Item (398/85-01-02) - Licensee committed to update the inventory list of sealed sources by January 1, 1986.
The inspector verified through discussions with the licensee and examination of licensee records that the inventory list of sealed sources had been updated by November 1, 1985.
3.
Review of Operations The inspector examined all areas of the site where special nuclear material (SNM) is handled to observe operations and activities in progress, to inspect the nuclear safety aspects of the facility, and to check the general state of cleanliness, housekeeping, and adherence to fire protec-tion rules.
a.
SNM Inventory The inspector reviewed licensee inventory records and determined that the inventory of SNM was within the limits authorized for License No.
b.
Housekeeping The inspector observed that housekeeping in the Building 245, Shipping-Receiving Area (Room B131-135 complex) had improved and was adequate. The licensee was storing contaminated trash in bags within a closed, operating walk-in hood which served to contain the trash.
Previously, it had been stored in bags on the floor of Room B131.
3 c.
Fire Control The inspector observed that the licensee was storing boxes of old records (flammable materials) in the liquid waste tank room (B-045),
underneath the tanks. There was a rate of rise heat detector but no fire sprinklers installed in the room.
Licensee representatives stated that storage of flammable material in this area would be re-examined.
This is an Inspector Followup Item (IFI 398/86-02-01).
d.
Container Labeling During examination of the Building 245, Room 143 - interim source storage area, the inspector observed a 55 gallon drum that was marked empty but was also marked as containing a neutron source. A radiation survey of the drum, conducted by the licensee at the request of the inspector, indicated that a neutron source was stored in the drum.
The empty marking on the drum was immediately obliterated by the licensee.
During examination of the Building 245 - outside loading dock, the inspector observed a U.S. 00T Type 7A, shielded container, which was not labeled with a radiation sign or marked empty. At the request of the inspector, the licensee verified that the container was empty and immediately marked the container with an empty sign.
Proper marking of containers was discussed at the exit interview.
The inspector stated that, while no NRC requirements had been violated in these two cases, a poor safety practice was indicated.
Licensee representatives stated that additional effort would be expended to assure that containers were properly labeled or marked.
This was identified as an Inspector Followup Item (IFI 398/86-02-02).
e.
Alpha Laboratory - Room A344, Building 222 Through discussions with licensee representatives, the inspector determined that actions have been initiated to remove the materials contaminated with uranium and plutonium from a hood located in the laboratory.
The contaminated materials will be packaged for shipment and will be transferred to a Department of Energy (DOE) laboratory for disposal. This action is being taken because existing burial sites will not accept materials containing in excess of 10 nanocuries of plutonium per gram of waste material. During this inspection, the licensee was preparing a series of procedures to address the removal, packaging and transportation of plutonium contaminated solutions from this laboratory.
The inspector suggested that because of the potential for spreading plutonium contamination, these procedures should be reviewed by the Radiation Safety Committee.
Licensee representatives stated that the procedures would be reviewed by either the Radiation i
Safety Committee or the Radiation Safety Review Subcommittee. This was identified as an Inspector Followup Item (IFI 398/86-02-03).
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4 4.
Nuclear Criticality Safety The inspector verified through observations that the licensee was maintaining the nuclear safety controls necessary to assure that no more than 300 grams of SNM was stored or used in any one area and that there was at least three feet separating each 300 gram batch of SNM as required by the facility license.
5.
Radiation Safety Committee The inspector determined, through discussions with licensee representatives and review of licensee records, that no meetings of the Radiation Safety Committee had been held since August 2, 1985.
The facility license requires meetings of the Radiation Safety Committee to be held at least annually.
According to licensee representatives, the next meeting of the Committee was scheduled to be held prior to May 31, 1986.
The Radiation Safety Review Subcommittee established an audit schedule to assure that all functions of the health physics group will be reviewed at least once every three years. The functions to be reviewed include:
radiation protection (posting, labeling, surveys etc.), personnel monitor-ing, instrumentation, waste management, environmental surveillance, material control, shipping and receiving, material accounting, training, organization, emergency planning, and use of nonionizing radiation sources. The inspector determined through discussions with the Subcommittee Chairman that the audit will include the availability and use of procedures,as required, for each function audited.
6.
Facility Changes and Modifications The inspector determined through examination of facilities and discussions with licensee representatives that there had been no facility changes or modifications which required notification to the NRC, within the scope of this inspection, since the last inspection.
7.
Radiation Protection a.
Source Leak Tests The inspector reviewed leak test records,for various sealed sources maintained by the licensee, for the period March, 1985 through March, 1986. The inspector found that the sources were leak tested at the intervals required by licensee conditions.
The inspector noted, during review of licensee records, that the licensee had developed an inventory of sources held under its license.
This inventory was computerized and indicated which sources are in storage, which sources are below the licensed activity limit and which have to be leak tested prior to use.
5 b.
Smear Surveys The inspector examined weekly smear survey data for the period September 1985 through April 14, 1986.
The data indicated that corrective actions were taken when the contamination exceeded 10 2
2 beta, dpm/100 cm alpha and/or 100 dpm/100 cm c.
Instrument Calibration The inspector reviewed the licensee's portable survey instrument calibration records for the period January 10, 1985 through March 25, 1986. The instruments were calibrated within six month intervals, as required by license conditions.
d.
Waste Compactor Air Sampling The inspector examined the records of air samples taken during opera-tion of the waste compactor from June 13, 1985 to April 2, 1986. No air samples in excess of about 10% of the maximum permissible concen-trations specified in 10 CFR 20, Appendix B, for unknown alpha or mixed fission product activity, were identified. The inspector noted that the licensee hao standardized the decay time for these samples at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as discussed during the last inspection.
e.
Personnel Dosimetry The inspector examined the licensee's 1985 personnel dosimetry records for radiation workers.
There was a total of 361 radiation workers at NBS during the year. Of the 361 workers, 164 registered no radiation dose and ten received a dose in excess of one rem. The maximum exposure for the year was about 2.2 rem. The maximum allowable exposure is five rem.
8.
Nonroutine Events The inspector determined through a review of licensee records and discussions with licensee representatives that there was one nonroutine event at this facility, withir. the scope of this inspection, since the last inspection.
The event was not required to be reported to the NRC.
On or about November 7, 1985, a Cesium-137 sealed source, in the form of a needle containing 24 mci Cs-137, was found on the floor in Room 143 of Building 245. The circumstances surrounding the discovery of that Cs-137 needle outside the storage shield (lead pig) had been investigated by the I
health physics group and independently reviewed by the Radiation Safety l
Review Subcommittee.
The licensee's procedure for the storage, handling,
6 and control of sources was examined in detail by the subcommittee. Several recommendations were made to facilitate the control of sealed sources.
The inspector verified that the licensee had initiated actions to address the subcommittee recommendations.
9.
Emergency Planning In accordance with a request from NRC's Office of Inspection and Enforce-ment, the inspector examined the licensee's emergency notification call list which is included in the Emergency Contingency Plan for the facility.
The inspector verified that the listed telephone numbers were accurate by calling each number.
10.
Environmental Surveillance The inspector examined licensee records of environmental TLD data obtained quarterly for the period January 1982 through December 1985.
The data indicated that there was no difference between the radiation level measured onsite and offsite and that the background radiation in the Gaithersburg, Maryland area ranged from 8 to 19 micro R per hour.
- 11. Organization The inspector determined that there had been several changes in the facility Health Physics group organization since the last inspection.
The Nuclear Material Accountability Assistant, Ms. L. Coker retired on January 3, 1986 and was replaced by Ms. B. Frey. A Health Physicist, P. R. Cassidy, assigned to the NBS research reactor health physics group, retired on March 29, 1986 and was replaced by K. H. Eggert. No inadequa-cies were identified by the inspector concerning the qualifications of those individuals.
12.
Training a.
Indoctrination Training for New Employees Safety indoctrination classes are administered to new employees, individually, by members of the Occupational Health and Safety Division staff during the first day of employment with NBS.
The indoctrination includes:
10 CFR 19 and 20; identification, dis-play and discussion of radiation and safety signs and labels; controls on access to contamination control areas, radiation areas and high radiation areas; and, alarms and emergency procedures.
7 Licensee records, reviewed by the inspector, indicated that all employees hired during 1985 were given the safety indoctrination.
b.
Refresher Training The licensee conducted a series of refresher training classes for personnel working with radiation or radioactivity at other than the NBS Reactor. These training sessions were conducted periodically during 1985. A total of 370 individuals were retrained during these sessions (540 hours0.00625 days <br />0.15 hours <br />8.928571e-4 weeks <br />2.0547e-4 months <br />) which covered topics including radwaste, prepara-tion of acquisition, use, and transfer forms; 10 CFR 19, 20 and 21; handling of radioactive material; and packaging of radioactive material.
Each individual was also issued IAEA leaflets which discussed the hazards and effects of radiation, and memoranda containing information describing radioactive waste disposal requirements.
c.
Health Physics Technician Training Licensee records, reviewed by the inspector, indicated that training sessions were held specifically for the health physics technicians during 1985. These training sessions covered the subjects of packaging and shipping; prep ~aration of contaminated waste for shipping; the QA Program for Shipping; federal regulations; health physics instructions (procedures); emergency response; use of supplied air masks; instru-ment calibration; ALARA concepts; air sampling techniques; bioassay calculations; and monitoring of high level radiation.
- 13. Transportation Activities a.
Radioactive Material Receipts The inspector examined licensee records for the receipt of radioactive materials for the period August 5, 1985 to April 1, 1986.
Smear and external radiation surveys were conducted to determine if the licensee was in compliance with the monitoring requirements of 10 CFR 20.205.
The licensee was found in compliance, b.
Radioactive Material Shipments The inspector reviewed licensee records for the shipment of radioactive materials for the period June 28, 1985 to April 14, 1986.
Shipping records indicated that all shipments were labeled, marked, placarded (if necessary), monitored for radiation and contamination, and recorded as required by federal regulations.
8 c.
Radioactive Waste Shipments The inspector reviewed licensee records for the shipment of radio-active waste. Between March 19, 1985 and April 15, 1986, the licensee made four shipments of radioactive waste.
The inspector determined from the records that each package was properly marked and labeled in accordance with U.S. DOT regulations; 10 CFR 61 and the burial site requirements.
For each shipment, the waste manifest appeared to properly identify the radioactive material chemical form, activity and stability as required by 10 CFR Part 61.
d.
Shipping Packages During a review of licensee records, the inspector determined that the licensee routinely used shipping packages identified as U.S. D0T 7A Type A steel drums.
The inspector requested copies of the certi-fication documentation for review to determine whether that the con-tainers were fabricated and tested in accordance with U.S. DOT re-quirements.
The licensee presented the inspector with documentation dated 1981 which contained the certifications required at that time.
However, several of the U.S. DOT requirements were modified during 1983. The licensee had received a letter dated August 1,1984 from the certifying organization which indicated that the 1981 certifica-tions would be updated prier to July 1, 1985. Upon questioning by the inspector, licensee representatives stated that the updated docu-ments had not been received. The licensee immediately contacted the certifying organization and requested the proper documents. This was identified as an unresolved item pending receipt of the revised cer-tification (UNR 398/86-02-04). An unresolved item is one about which more information is required in order to ascertain where it is acceptable, an item of noncompliance, or a deviation.
14.
Inspector Accompaniment The inspector was accompanied during a portion of this inspection by Mr. A. W. Grella from the NRC's Office of Inspection and Enforcement.
Mr. Grella assisted in the review of licensee transportation activities and implementation of 10 CFR Part 61.
15.
Exit Interview The inspector met with the licensee representatives indicated in paragraph 1 at the conclusion of the inspection on April 17, 1986.
The inspector summarized the scope of the inspection and the findings.
At no time during this inspection was written material provided to the licensee by the inspector.
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